All they wanted to do was contest liability, but Appeals said sorry, you should’a done that when you got the SNOD.

“The Sherwoods admit with admirable honesty that Dr. Brent Sherwood received the notice of deficiency, but didn’t pay close attention to it because he was studying for his board certification — and we assume with some confidence that this is an exam even harder than the bar or CPA licensing exams. But his perhaps understandable focus on his profession and his simultaneous life-saving employment as a traveling emergency-room doctor doesn’t mean that the settlement officer made either an error of fact or one of law in concluding that the Sherwoods can’t challenge their underlying liability. See IRC § 6330(c)(2)(B).” Order, at p. 2.

And at Appeals Dr Brent and Janet K didn’t ask for an IA, or an OIC.

No matter how hard the exam, petition the SNOD. Or else you fail in Tax Court.

An author, teacher, advocate and trusted advisor, Lew Taishoff is a New York City-based attorney with 51 years of experience in corporate and individual tax and real estate matters. He is an Enrolled Agent, examined and admitted to practice before the Internal Revenue Service, and admitted to practice before the United States ... Continue reading →